SYN+AIR PRIVACY POLICY

1. About Sparsity

• Sparsity-Technologies (formally Sparsity, S.L.) is a spin-out of the UPC (Universitat Politècnica de Catalunya) created on March 2010 to commercialize and provide services based on the technologies developed at DAMA-UPC.
• Sparsity is involved in the collection of questionnaires for T3.1 and T4.4 as well as in the activities of T6.2 for the formation of an external advisory board and for the organization and execution of the two stakeholder workshops.

2. Aim of this Privacy Policy and definitions

• The aim of this privacy policy is to ensure that the processing of personal data carried out by Sparsity during the SYN+AIR project complies with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR).
• Personal data are any information which are related to an identified or identifiable natural person. The data subjects are identifiable if they can be directly or indirectly identified, especially by reference to an identifier such as a name, an identification number, location data, an online identifier or one of several special characteristics, which expresses the physical, physiological, genetic, mental, commercial, cultural or social identity of these natural persons. In practice, these also include all data which are or can be assigned to a person in any kind of way. For example, the telephone, credit card or personnel number of a person, account data, number plate, appearance, customer number or address are all personal data.
• The term “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

3. Compliance with the GDPR during the SYN+AIR project

• All personal data collected or processed by Sparsity during the SYN+AIR project will be used solely for the purposes of the project as specified in in the GA 894116.
• Personal data collected or processed by Sparsity during the SYN+AIR project may only be shared with the following organizations of the consortium for the purposes of the project: UNIVERSITAT POLITECNICA DE CATALUNYA (UPC), AETHON SYMVOULI MICHANIKI MONOPROSOPI IKE (AETHON), Univerzitet u Beogradu – Saobracajni fakultet (UB-FTTE), POLITECNICO DI BARI (POLIBA).
• Any electronic communication, including any attached files, sent from or to Sparsity is confidential.
• Electronic communications are stored exclusively on servers located in Sparsity premises or in premises of the website syn-air.eu hosting company. Our hosting company is Siteground and their servers are located in Eemshaven (Netherlands). The website we have built is for people to find information regarding the SYN+AIR project. For the newsletter purpose, we will use ‘Mailchimp’ to gather emails, prepare and send the newsletters. Once the project ends, we will erase the database and delete the account. The intention of gathering emails is purely for dissemination purposes and we will not process the emails in any other way. Users accept the Terms and Conditions in order to be included in our Mailchimp contact list.
• The security of stored electronic communications and personal data is ensured through Mailchimp Terms & Conditions and security measures.
• The collected personal data will be retained up to 6 months after the end of the project, unless further retention is imposed by law.

• Notwithstanding the obligations incumbent on Sparsity based on legally binding provisions, Sparsity will never intentionally reveal personal data allowing the deduction of your identity to any third parties, including your e-mail address, without your prior consent or other legal basis.
• No personal data will be transferred outside of the EU with the exception of transfers to UB-FTTE, which is situated in Serbia. UB-FTTE has submitted a general statement signed by the responsible person of the organization according to which in case personal data are collected in the Republic of Serbia, the processing of such data and their transfers will be carried out in compliance with the Law on Protection of Personal Data (Official Gazette of the Republic of Serbia, No. 87/2018). In case personal data are collected within the EU, the processing of personal data and their transfers will be carried out in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

4. Your rights

• When we collect and use your personal data, you have a number of rights that you can exercise as described below.
• You have the right to access your personal data, which means that you can ask us to provide you with information about the personal data we have about you. You can even request a copy of your personal data.
• You have the right to ask us to correct your personal data if you can prove that the personal data, we process about you is incorrect, incomplete or out of date. Please specify the context in which we use your personal data (e.g., to send you newsletters or to respond to a request), so that we can assess your request quickly and accurately.
• If we have asked for your consent to the collection and use of your personal data, for example to send you newsletters, you have the right to withdraw this previously given consent.
• You can ask us to delete your personal data if it is no longer necessary for the purposes for which it was collected, if its collection was unlawful or if you have successfully exercised your right to withdraw your consent or your right to object to the processing of your personal data. Where any of these circumstances apply, we will delete your personal data immediately unless we are prohibited from deleting your personal data by law, regulatory obligations or administrative or court orders.
• When we process your personal data on the basis of our own legitimate interests, you have the right to object to our processing of your personal data. However, we will ask you to describe your particular situation giving rise to the request. We must then balance your situation against our interests. If this balancing exercise results in your situation outweighing our interests, we will stop processing your personal data.
• If you have any complaints regarding the processing of your personal data by Sparsity, you can always contact the person in charge of privacy within our organization: larri@sparsity-technologies.com
• If you are still not satisfied with our response, you can lodge a complaint with the competent data protection authority, APDCAT: https://apdcat.gencat.cat/ca/inici

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Josep Lluís Larriba Pey